The regulatory gap between the EU and the US is staggering. The EU has banned or restricted over 1,600 chemicals in cosmetics. The US FDA has banned or restricted just 11.
In the EU, cosmetics are regulated under Regulation (EC) No 1223/2009. This comprehensive law requires safety assessments before products reach the market, uses a precautionary principle approach, and maintains lists of banned, restricted, and permitted substances (Annexes II through VI).
In the US, the FDA’s authority over cosmetics has historically been limited. The Federal Food, Drug, and Cosmetic Act (FD&C Act) hasn’t been significantly updated since 1938. The 2022 Modernization of Cosmetics Regulation Act (MoCRA) added some new requirements, but enforcement remains limited.
Key differences: The EU requires pre-market safety assessment; the US does not. The EU operates on the precautionary principle (restrict first if there’s concern); the US generally requires proof of harm. The EU mandates full INCI labelling; the US allows the ‘fragrance’ loophole.
The EU’s REACH regulation adds another layer of protection, requiring manufacturers to register and provide safety data for chemicals used in the EU, including those in cosmetics. This means ingredients are evaluated for endocrine-disrupting properties.
For consumers in the EU, this means your products have undergone more rigorous safety assessment. But ‘more regulated’ doesn’t mean ‘perfectly safe’ — many chemicals still haven’t been fully evaluated, and the science evolves. That’s why tools like EDScan exist: to help you stay informed as knowledge advances.
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